Interpretation Response #08-0263 ([Foth] [Ms. Sheryl Pham])
Below is the interpretation response detail and a list of regulations sections applicable to this response.
Interpretation Response Details
Response Publish Date:
Company Name: Foth
Individual Name: Ms. Sheryl Pham
Location State: WI Country: US
View the Interpretation Document
Response text:
December 11, 2008
Ms. Sheryl Pham
Foth
2737 South Ridge Road
Suite 600
P.O. Box 12326
Green Bay, WI 54307-2326
Ref. No. 08-0263
Dear Ms. Pham:
This responds to your October 17, 2008 letter requesting clarification on the §173.150 exceptions in the Hazardous Materials Regulations (HMR; 49 CFR Parts 171-180).
Specifically, you ask whether the exceptions apply to your client"s shipping operations.
According to your letter, your client ships a combustible liquid (solvent waste) that does not meet the definition of a hazardous waste in non- bulk packaging. You request confirmation that this shipment of combustible liquid as well as shipments of less than 1000 pounds of hazardous waste in non-bulk packaging, are excepted from placarding, training, registration, and security requirements.
Under §173.150(f)(2), the HMR do not apply to a material classed as a combustible liquid in a non-bulk packaging unless the combustible liquid is a hazardous substance, a hazardous waste, or a marine pollutant. Therefore, the HMR do not apply to your shipment of non-hazardous waste combustible liquid in non-bulk packaging.
Shipments of less than 1000 pounds of hazardous waste in non-bulk packaging that do not meet the definition of any other hazard class are excepted from placarding, registration, and security plan requirements. However, the training requirements in Subpart H of Part 172 do apply to such shipments.
I hope this answers your inquiry.
Sincerely,
Charles E. Betts
Chief, Standards Development
Office of Hazardous Materials Standards
173.150(f)(2)
Regulation Sections
| Section | Subject |
|---|---|
| 173.150 | Exceptions for Class 3 (flammable and combustible liquids) |